The U.S. EPA regional office in Boston and the Massachusetts Water Resource
Administration (MWRA) have come up with a so-called plan to clean up the
notorious Boston harbor. We think you should be aware that this plan is
contrary to everything this agency is supposed to stand for. EPA is supposed
to reduce pollution. Instead, this plan allows polluters to continue to
dump over a ton a day of toxic wastes into the Boston sewers. The plan
then calls for the people of Massachusetts to pay over six billion dollars
to build sewage treatment plants which will transfer the toxic laden wastes
from Boston harbor to food supplies in Texas and Florida and to dumps in
suburban Boston which will inevitably pollute drinking water supplies.

The largest polluter of the Boston sewer system is the Polaroid Corporation.
Some of the other well known companies which dump toxic chemicals and petroleum
into the Boston sewer and Boston harbor include; Proctor & Gamble,
Monsanto, Raytheon, Gillette, Honeywell, TRW, Hewlit Packard, General Electric,
The U.S. Army, GTE, General Motors, Exxon, The Boston Globe, and BASF.

A federal court has ordered the State to stop dumping its sewage sludge
into the harbor. Under the clean Water Act, the EPA Boston regional office
and the MWRA have the mandate and the authority to require these polluters
to eliminate or significantly reduce their toxic discharges. If this were
done, the resultant sewage sludge would be free of toxic chemicals and
could safely be used as fertilizer. But instead, the plan allows the polluters
to continue to pollute. The federal and state authorities in Massachusetts
apparently have no stomach for regulating big corporations.

As a result, their plan calls for over six billion dollars worth of
sewage treatment to produce a sludge contaminated with toxic chemicals.
If the authorities had done the job they are being paid by the taxpayers
to do, that is regulating polluters, the cost to the taxpayers would be
much less than the planned six billion dollars.

This sludge is too filthy to be used as fertilizer under Massachusetts
law. It is too filthy for all of New England and New York. It falls far
short of the standards that EPA proposed in February under section 405
of the Clean Water Act. The reaction of these agencies to these facts is
shocking. These agencies, charged with protecting the environment, ignore
the proposed federal regulations and proceed to shop around for states
with weak environmental laws where they can market their contaminated sludge
as fertilizer. They have focused in on the southeast and on Texas and Florida
in particular.

This is the kind of irresponsible behavior one associates with some
of the worst polluters. It is incomprehensible when practiced by government
environmental protection agencies.

Furthermore, the plan provides that any sludge which cannot be marketed
(which is likely to be most of it) will be dumped in a landfill the MWRA
is proposing to set up in Walpole, Massachusetts. This has caused considerable
consternation among the citizens of Walpole and adjacent Norfolk. They
have a legitimate concern about pollution of their groundwater, which they
depend on for their drinking water, and for nearby streams and lakes.

However, the EPA regional office and the MWRA have not been moved by
the citizens concerns. They may be too timid to stop Polaroid and other
big corporations from discharging toxic wastes but they do have the courage
to face down the citizens of Walpole and Norfolk and to dump Polaroid's
waste in their back yard.

In trying to con the public into accepting the landfill, the environmental
impact statement prepared by the EPA regional office contains such egregious
statements as:

Escape of leachate to the soil beneath the lined area should
not be expected for a properly operated and maintained double-lined landfill
that is capped after filling of each cell.

The occurrence of an undetected and thus, unrepaired, leak
in the proposed Walpole MCI landfill liner system would be unlikely.

... there would be sufficient time for such a leak to be detected and
corrective action to be taken.

... any leak which did occur in the landfill liner could be
quickly repaired...

A properly designed and executed monitoring plan would detect
any landfill leaks in sufficient time to remediate any groundwater contamination
before significant impacts occurred...

Our experience and knowledge of landfills goes back more than a decade.
Mr. Sanjour was formerly Chief of the [EPA] Hazardous Waste Assessment
and Technology Branch where he supervised studies of the damages done by
hazardous waste disposal and the technology for disposing of hazardous
wastes. Mr. Kaufman is a senior hazardous waste management specialist
and former chief investigator of hazardous sites [at EPA]. Both of us have
written articles and have given expert testimony in Congress and in the
courts on this subject.

We have heard lies, like those quoted above, many times by landfill
promoters trying to con a gullible public. Every year seems to bring a
new crop of hustlers for the latest in state-of-the-art
landfills, "guaranteed not to leak", only to have their landfills end
up on the "Superfund" list or undergoing "corrective action" a few years
later. We are chagrined to see EPA engaged in this con.

Neither EPA nor the Congress of the United States shares the Boston
EPA regional office's high opinion of the reliability of landfill technology.
As you know, Congress has such a low opinion of landfills that they passed
legislation which greatly restricts their use. In passing that legislation,
the House Report contains the following admonition for you, the Administrator
of EPA:

The Committee reiterates its intention that land disposal be
used principally as a last resort.

The following factors are to be considered by the Administrator
in determining whether one or more methods of land disposal may not be
protective of human health and the environment:...

the design and management uncertainties involving the long-term
inability of liners and leachate collection systems to prevent water migration
from the facility,

the uncertainties associated with ground water monitoring,...

The philosophy of both the Hazardous and Solid Wastes Amendments of 1984
and section 405 of the Clean Water Act is that you cannot rely on "gimmicks"
such as liners and leachate collection systems and monitoring systems to
protect groundwater from the toxic wastes dumped in the ground. Rather
the waste itself must be rendered incapable of polluting the groundwater
before it is dumped.

EPA was supposed to have issued standards under section 405 more than
ten years ago. They were only first proposed last February. It will be
many more years before they are finalized. The proposed Walpole landfill
does not meet the proposed EPA standards but the EPA regional office can
ignore that too because the standards aren't final.

The citizens of Walpole and Norfolk, Massachusetts are, therefore, the
victims of EPA's failure to live up to it's responsibilities in two respects;
it's failure to require Boston's industrial polluters to meet reasonable
pre-treatment standards, and it's failure to issue sewage sludge regulations
under section 405.

They are not the only victims. Every taxpayer in Massachusetts is subsidizing
the industrial polluters and they may have to pay millions more to clean
up the Walpole landfill in the very likely event that it leaks and pollutes
the groundwater. The people of Texas and Florida may also be victims if
contaminated Boston sludge is used as fertilizer in their states.

It is EPA's job to prevent pollution, not to pass it on and spread it
around.